The International Athlete

Cross-border NIL, tax, visas, and the two-entity model

Tens of thousands of international athletes play college and professional sport in the US, and when the money arrived they found the playbook everyone else uses does not fit them. Their visa limits what they can do, their income is taxed in two countries at once, and the usual advice (form an LLC and route the money through it) can make it worse. This guide explains why the ordinary structures fail, what the visa actually allows, how the three-layer tax picture works, and the two-entity structure that holds up when an immigration officer, a tax authority, and a school compliance office all look at once.

“A structure that only works if nobody reads it is not a structure. It is a time bomb.”

Brandon Leopoldus, Esq.